BellaVista Capital, Inc.
                          420 Florence Street Suite 200
                               Palo Alto, CA 94301

                                  June 25, 2007


BY EDGAR
- --------

Jessica Barberich
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549

        Re:      BellaVista Capital, Inc. (the "Company")
                 Item 4.02 Form 8-K Filed June 15, 2007
                 SEC File No. 0-30507

Dear Ms. Barberich:

     We are responding to the comment in your letter dated June,  2007 regarding
the above-referenced filing.

     The  Company's   officers  have   reconsidered  the  effectiveness  of  its
disclosure  controls and procedures as of September 30, and December 31, 2006 in
light of the restatement of financial information as of those dates. The Company
will address this  reconsideration  and the related  conclusions  in the filings
that contain our restated financial statements.

     The Company hereby acknowledges with respect to the above referenced matter
that

     o    the  Company is  responsible  for the  adequacy  and  accuracy  of the
          disclosure in this filing;
     o    staff  comments or changes to disclosure in response to staff comments
          in the filings  reviewed by the staff do not foreclose the  Commission
          from taking any action with respect to the filing; and
     o    the  Company  may  not  assert  staff  comments  as a  defense  in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

          BellaVista Capital, Inc.

          By:  /s/ MICHAEL RIDER
               -----------------------------
               Michael Rider, President